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SEC Company Response from AVADEL PHARMACEUTICALS PLC (AVDL) (CIK 0001012477) — Sep 8, 2022

AVADEL PHARMACEUTICALS PLC (AVDL) (CIK 0001012477)
Date: Sept. 8, 2022 · CIK: 0001012477 · Accession: 0001104659-22-098527

AI Filing Summary & Sentiment

File numbers found in text: 333-267198

Date
September 8, 2022
Author
AVADEL PHARMACEUTICALS PLC
Form
CORRESP
Company
AVADEL PHARMACEUTICALS PLC (AVDL) (CIK 0001012477)

Letter

Re: Avadel Pharmaceuticals plc

VIA EDGAR

September 8, 2022

United States Securities and Exchange Commission

Office of Life Sciences

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Acceleration Request for Registration Statement on Form S-3

File No. 333-267198

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Avadel Pharmaceuticals plc (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to September 12, 2022, at 4:01 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP, request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP by calling Finnbarr Murphy at (212) 459-7257. If you have any questions regarding this request, please contact Finnbarr Murphy of Goodwin Procter LLP at (212) 459-7257.

Sincerely,
AVADEL PHARMACEUTICALS PLC

Show Raw Text
CORRESP
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filename1.htm

VIA EDGAR

September 8, 2022

United States Securities and Exchange Commission

Office of Life Sciences

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Avadel Pharmaceuticals plc

Acceleration Request for Registration Statement on Form S-3

File No. 333-267198

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Avadel Pharmaceuticals plc (the “Company”)
hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”)
be accelerated to September 12, 2022, at 4:01 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel,
Goodwin Procter LLP, request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration
request, the Company acknowledges that it is aware of its responsibilities under the Act.

Once
the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP by calling Finnbarr Murphy
at (212) 459-7257. If you have any questions regarding this request, please contact Finnbarr Murphy of Goodwin Procter LLP at (212) 459-7257.

    Sincerely,

    AVADEL PHARMACEUTICALS PLC

    /s/ Thomas S. McHugh

    Thomas S. McHugh

    Chief Financial Officer

cc: Gregory J. Divis, Avadel Pharmaceuticals plc

Jerad G. Seurer, Esq., Avadel Pharmaceuticals
plc

Robert E. Puopolo, Esq., Goodwin Procter
LLP

Finnbarr D. Murphy, Esq., Goodwin Procter LLP